The coronavirus (COVID-19) pandemic has disrupted almost every industry, including healthcare. At the same time, Forbes called home healthcare services a "bright light" with an even brighter future. They attributed part of the industry's success to a willingness to adapt by embracing such new tech as telehealth. At least temporarily, Centers for Medicare and Medicaid Services (CMS) waivers for some regulatory requirements have also helped providers improve access during the pandemic. That's especially true for homebound and high-risk patients who cannot or do not want to leave home.

Despite their industry's relative strength and ability to adapt, home health agencies still face many challenges, including delivering services during a global pandemic and ensuring fair reimbursement from Medicare and other government programs for those services. While waivers have offered temporary relief, home health providers should still expect to document and justify billing after waivers expire. Therefore, consider the following strategies to manage reimbursement during the COVID-19 pandemic, or future pandemics:

Handle Disaster Relief Waivers Carefully

Temporary waivers began on March 27, 2020. Major points of these temporary regulatory waivers included:

• They extended rap auto cancellation to a period of 90 days.
• They also extended the five-day completion for comprehensive assessments to 30 days.
• They offered the Medicare telehealth waiver to help support access to patients during the pandemic.
• They waived onsite supervision visitation requirements.
  
  • They paused review choice for Illinois, Ohio and Texas. Additionally, they extended health agencies in Florida and North Carolina until Jan. 1, 2021.
  • Note: Home health agencies that use these temporary exceptions will be flagged for post-claim review later. Therefore, while your agency shouldn’t be discouraged from taking advantage of this regulatory relief, it’s critical to document everything accurately and completely to help ensure you retain your reimbursement funds.

Account for Review Choice Demonstration

Review choice demonstration, often called RCD, ensures beneficiaries qualify to receive Medicare home health services. Beginning on March 29, claims were not required to go through pre-claim RCD review. In some states, this pause has already been released. Without a pre-claim review, home health agencies should expect a post-claim review if their claims omit the unique tracking number, or UTN.

Therefore, best practices include:

• Ensuring timely submissions whenever possible, including a UTN.
• Keeping valid documentation on file in case of an additional documentation request, or ADR.

Manage ADRs and Audit Responses Effectively

When ADRs and/or audits do occur, home health agencies can prepare in advance by being proactive in conducting regular self-audits. On a technical level, this means reviewing the following:

• Beneficiary election statement
• Components of certifications and recertifications
• Plan of care
• Signatures and dates

From an eligibility point of view, it’s also important to review the following:

• Coverage guidelines
• Supporting documentation for all services billed
• Physician notes

Financial Implications:

• The failure to promptly submit documents for ADRs or to get a favorable decision will result in recoupment of funds.

Good preparation will help home health agencies deal with audits and ADRs efficiently and successfully. Suggested steps include:

• Use a documentation checklist to ensure inclusion of all required documents.
• Use your MAC's LCD when including documents and creating a cover letter.
• If needed, add in supporting eligibility documentation.
• Ensure each page is legible and clear.
• Add page numbers to the top-right corner of each page.
• Don’t use staples.
• Keep an agency copy of the documentation on file.
• Never alter any documentation.
• Submit documentation promptly for receipt before the due date.

In the end, we at Richter recommend a four-pronged strategy to maximize reimbursement and reduce the threat of audits and recoveries:

1. Encourage collaboration between patients, family members and the agency: Ensure clients understand what services Medicare allows and under which conditions. For instance, providers that offer telehealth need to ensure that patients or family caregivers know what's covered.

2. Understand billing and documentation guidelines: Home health agencies must understand the documentation they need to get services reimbursed and to maintain that documentation in good order.

3. Develop processes to ensure timely claims billing: Of course, quicker billing helps ensure faster payments from Medicare, other insurance, and patients.

4. Perform self-audits and reviews of documentation regularly: Instead of leaving documentation to chance, develop checklists and make sure documents conform to them.

Basically, the same good business processes that help maximize reimbursement and reduce the chance of recoveries at other times will help home health agencies sustain themselves well during the current pandemic. Agencies should not skip steps because they have temporary waivers for some filing requirements. On the other hand, the same effective processes that can help agencies run smoothly through pandemic-related disruption will also help them emerge stronger, more effective, and better able to serve their patients in the future.

In normal times and in particular, during a disruptive pandemic, high-quality home health consulting services can help ease the administrative burden of accounting, billing and compliance by providing efficient workflows and procedures.

To aid you in promoting financial health for your home health agencies and other issues surrounding COVID-19, we have developed a COVID-19 Resource Center which is regularly updated with the latest information.